FOR - Pick n Pay

1 CODE OF ETHICS. FOR. 1. Table of contents A message from Pick n Pay's Chief Executive Officer .. 4. INTRODUCTION .. 4. HOW TO USE THIS DOCUMENT: .. 5. PART 1 sets out the fundamental principles of Pick n Pay .. 5. PART 2 consists of a Code of Conduct for Business Partners of Pick n Pay.. 5. PART 3 consists of a Code of Ethics for employees of Pick n Pay .. 5. PART 1 .. 6. PICK N PAY'S FUNDAMENTAL PRINCIPLES .. 6. Our core 6. Four legs of the table .. 6. Sustainable business .. 6. Building of sustainable communities.

2 7. MISSION AND VISION .. 7. Our stakeholder pledge .. 7. Integrity in doing good business .. 9. Fair competition .. 9. Environmental responsibility .. 9. Health and Safety for employees and 10. Communications on Behalf of Company (PR, media, speeches, articles) .. 10. Restrictive trade practices .. 10. Anti-Child labour .. 11. 11. Protecting company privacy .. 11. INTEGRITY IN SUPPORTING COMMUNITIES .. 11. Social Responsibility .. 11. Customer Service .. 12. PART 2 .. 14. CODE OF CONDUCT FOR BUSINESS PARTNERS OF PICK N PAY.

3 14. Child labour .. 14. Forced labour .. 14. Health and Safety .. 15. Wages, hours of work and entitlements .. 15. Discrimination .. 15. Freedom of association and the right to collective bargaining .. 15. Harsh or cruel treatment .. 15. 16. PART 3 .. 17. CODE OF ETHICS .. 17. FOR EMPLOYEES OF PICK N 17. APPLICATION AND GENERAL OBLIGATION OF CODE OF ETHICS .. 17. Application of Ethics .. 17. General Obligations of Employees .. 17. Obligations of Pick n Pay Management .. 17. Reporting ethical concerns .. 18. INTEGRITY IN THE 19.

4 Use of Pick n Pay resources and assets: .. 19. Conflicts of Interest .. 20. Gifts, Entertainment, Gratuities, Favours and Other Items of Value to/from Customers, Suppliers, Vendors, Contractors, Government Employees .. 20. Gifts from Personal Friendships .. 22. Customer, Supplier, and Vendor Relationships .. 22. Personal relationship with other employees .. 23. 2. Financial investments .. 23. Financial integrity .. 24. Whistle blowing .. 25. Code of 25. Substance abuse (alcohol, drugs) .. 26. Discrimination .. 26. Harassment.

5 26. Sexual harassment .. 26. Employee remuneration .. 27. Political Contributions .. 27. 3. A message from Pick n Pay's Chief Executive Officer Dear Colleagues Pick n Pay places great emphasis on social responsibility. The way in which we conduct ourselves in the running of our business should be as ethical as our contribution to society. The set of values to which we prescribe has been detailed in this policy document and should be used as a standard for all our business partners. We wish to build and maintain mutually beneficial relationships with all our stakeholders, whether employees, customers, suppliers, shareholders, franchisees or the communities in which our businesses are situated.

6 This policy document is intended to raise ethical awareness. It contains ethics for everyday events that occur in the business. It should help to assure customers, suppliers, stakeholders and competitors of the integrity of the Pick n Pay business ethic, and give them confidence in their dealings with the company. It is not intended to be a detailed description of behaviour norms. All people to whom this Code of Ethics applies shall observe their ethical obligations in such a way as to carry on business by fair commercial INTRODUCTION.

7 Competitive practices, and without causing harm. Pick n Pay is committed to dealing with legal entities that apply ethical and legal employment practices, as well as sustainable environmental practices, during the course of its business interactions, which may include sourcing, franchising and commercial operations. Pick n Pay, as a socially responsible organisation, is required to ensure that our business partners adhere to certain minimum standards. This has become increasingly necessary as Pick n Pay expands its operations into countries beyond South Africa.

8 These standards ensure that employees are managed in a socially responsible fashion, and that our impact on the environment is minimised. This Code of Ethical Conduct ( Code of Ethics ) is binding as a minimum standard on all business partners of Pick n Pay, irrespective of whether they are located in South Africa 4. or around the world. In addition, our Business Partners are expected to ensure that all of its sub-contractors or secondary suppliers comply with this Code. All business partners of Pick n Pay will be assessed against the standards of the Code.

9 Please note that Pick n Pay takes compliance with the Code very seriously. HOW TO USE THIS DOCUMENT: PART 1 Sets out the fundamental principles of Pick n Pay PART 2 Consists of a Code of Conduct for Business Partners of Pick n Pay. Business partners are encouraged to read Part 2 so as to be aware of the standards of conduct and ethics that are required from Pick n Pay's employees. PART 3 Consists of a Code of Ethics for employees of Pick n Pay 5. PART 1. PICK N PAY'S FUNDAMENTAL PRINCIPLES. Our core principles The core principles that constitute Pick n Pay's business activities include: Maintaining abiding values, in spite of business practices changing with time.

10 Fostering respect for individuals, not as a strategic advantage, but because it is morally correct. Acknowledging the difference between timeless principles and daily business practices. Sticking to values even if this appears to put us at a competitive disadvantage. Four legs of the table This principle follows a simple analogy: The business is essentially likened to a table supported by four legs, on top of which the consumer is positioned. Each leg is required to be equally strong so that the table may remain balanced and upright.